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HomeMy WebLinkAbout#5156_2016_0127_BS_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed: Date Forwarded to Reviewer: Reviewed by: Date Review Completed: Cover Letter to use: Unit Supervisor/Chemist III: Date Received: Date Forwarded to Linda: Date Mailed: 5156 Duke Energy- McGuire Nuclear Station Field Maintenance Beth Swanson, Gary Francies 1 /27/2016 2/5/2016 2/8/2016 Tonia Springer 2/8/2016 ❑ Insp. Initial ❑ Insp. No Finding ® Corrected Gary Francies 2/8/2016 2/15/2016 2/16/2016 ❑ Insp. Reg. ❑ Insp. CP ❑ Insp. Reg. Delay Water Resources ENVIRONMENTAL QUALITY February 16, 2016 5156 Mr. John Williamson Duke Energy- McGuire Nuclear Station 12700 Hagers Ferry Rd Mail Code: MG01 EM Huntersville NC, 28078 PAT MCCRORY DONALD R. VAN DER VAART S. JAY ZIMMERMAN SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Williamson: Enclosed is a report for the inspection performed on January 27, 2016 by Beth Swanson and Gary Francies. Since the Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a response is not required. The staff is commended for taking the initiative in correcting the Findings in such a timely manner. For Certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H .0800. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by email, or if you have questions or need additional information, please contact us at (828) 296-4677. Attachment cc: Beth Swanson Master File Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Water Sciences Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location:4405 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-733-3908 l FAX: 919-733-6241 Internet: http://portal.ncdenr.arglweb/wgllablcert LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: Duke Energy- McGuire Nuclear Station NCO024392 12700 Hagers Ferry Rd Mail Code: MG01 EM Huntersville NC, 28078 5156 January 27, 2016 Field Maintenance Beth Swanson and Gary Francies John Williamson, Pete Bynum and Macrae Walters This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. Staff was forthcoming and helpful in answering our questions. They were diligent in implementing corrective actions and recommendations and are to be commended for their effort. Proficiency Testing (PT) samples were analyzed for all certified parameters for the 2015 proficiency testing calendar year and the graded results were 100% acceptable. Contracted analyses are performed by Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Certification #248). Current Quality Assurance Policies for Field Laboratories and Approved Procedures for the analysis of the facility's currently certified parameters were provided at the time of the inspection. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: The laboratory needed to increase the documentation of purchased materials and reagents, as well as documentation of standards and reagents prepared in the laboratory. Traceability information was being documented on the reagent bottles, but the linkage is lost once the bottles are discarded. The Quality Assurance Policies for Field Laboratories document states: All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date Received, Date Opened (in use), Vendor, Lot Number, and Expiration Date A system (e.g., traceable Page 2 #5156 Duke Energy- McGuire Nuclear Station identifiers) must be in place that links standard/reagent preparation information to analytical batches in which the solutions are used. Documentation of solution preparation must include the analyst's initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for chemicals, reagents standards and consumables used for a period of five years Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Notification of acceptable corrective action (i.e., updated Total Residual Chlorine (TRC) and pH benchsheets with spaces for the required traceability information (i.e., vendor, lot number, expiration date, and date opened) were implemented by February 4, 2016) was received by email on February 4, 2016. No further response is necessary for this Finding. Comment: Improper error correction was noted during the inspection. Error corrections were not dated. The Quality Assurance Policies for Field Laboratories document states: All documentation errors must be corrected by drawing a single line through the error so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite-Out®, correction tape or similar products designed to obliterate documentation are not to be used. Write the correction adjacent to the error. The correction must be initialed by the responsible individual and the date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Notification of acceptable corrective action (i.e., the requirement is in the facility's "Procedure and Work Instruction Use and Adherence" document and was also reiterated to all analysts during a meeting and through email on February 3, 2016) was received by email on February 4, 2016. No further response is necessary for this Finding. Chlorine, Total Residual Comment: The laboratory was not analyzing a reagent blank when using lab water to prepare standards. The Approved Procedure for the Analysis of Total Residual Chlorine states: Each day that prepared standards are analyzed, a reagent blank must be analyzed A reagent blank is made from the same laboratory water source used to make quality control and/or calibration standards with DPD. The concentration of reagent blanks must not exceed 50% of the reporting limit (i.e., the lowest calibration or calibration verification standard concentration), unless otherwise specified by the reference method, or corrective action must be taken. Notification of acceptable corrective action (i.e., the facility's TRC procedure was updated with the requirement to analyze a reagent blank when lab water is used to prepare standards which will be implemented during the next TRC calibration curve verification or sooner if compliance samples must be analyzed) was received by email on February 4, 2016. No further response is necessary for this Finding. Comment: To this point, no compliance samples have been analyzed for TRC, but the facility is being issued a new permit this year which may include TRC monitoring. The laboratory is currently using a Hach Pocket II colorimeter. As such, the laboratory is reminded that this instrument is only acceptable if the new permit either has no limit or a limit >100 ug/L (i.e., >0.1 mg/L). IH Comment: The obtained value of the check buffer was not consistently recorded. The benchsheets showed that some analysts were only writing the true value of the pH buffer. The Approved Procedure for the Analysis of pH states: The following must be documented in indelible ink whenever sample analysis is performed: Value obtained for the check standard buffer (verification of + 0.1 S U ). Notification of acceptable corrective action (i.e., an updated calibration benchsheet with spaces labeled "Actual Buffer Value" was put into use by February 4, 2016) was received by email on February 4, 2016. No further response is necessary for this Finding. Page 3 #5156 Duke Energy- McGuire Nuclear Station Comment: The true value for the calibration and check buffers were not documented on the benchsheet. The benchsheet did not distinguish which buffers were used for calibration and which were the check (i.e., QC). The Approved Procedure for the Analysis of pH states: The following must be documented in indelible ink whenever sample analysis is performed: True values of buffers used for calibration and true value for the check standard buffer. Notification of acceptable corrective action (i.e., an updated calibration benchsheet with spaces labeled "Expected Buffer Value" and "Expected QC Value" was put into use by February 4, 2016) was received by email on February 4, 2016. No further response is necessary for this Finding. Comment: The laboratory performs an annual Automatic Temperature Compensator (ATC) verification on the pH meter, which is not required by NC WW/GW LC. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for NPDES permit #NC0024392 for July, September, and November, 2015. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: All Findings noted during the inspection were adequately addressed prior to the completion of this report. The inspectors would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Beth Swanson Date: February 5, 2016 Report reviewed by: Tonja Springer Date: February 8, 2016